View source for NL-16-0307, Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times

{{Adams
| number = ML16109A338
| issue date = 04/18/2016
| title = Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times
| author name = Pierce C
| author affiliation = Southern Co, Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000424, 05000425
| license number = 
| contact person = 
| case reference number = NL-16-0307
| document type = Letter type:NL, Response to Request for Additional Information (RAI)
| page count = 25
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Charles R. Pierce               Southern Nuclear Regulatory Affairs Director     Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205 992.7601                  SOUTHERN * \
NUCLEAR A SOUTHER N COMPAN Y Docket Nos.: 50-424                                                   NL-16-0307 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t
to Permit the use of Risk Informed Completion Times Ladies and Gentlemen:
By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request to permit the use of Risk Informe d
Technical Specification (TS) Completion Times in accordance with Nuclear Energy Institute (NEI) Report 06-09, Revision 0, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)
Guidelines, at the Vogtle Electric Generating Station. The SNC submittal was supplemented by letters dated August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, and May 5, 2015. By letter dated December 17, 2015, the Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) regarding the SNC TS amendment request.
By letter dated February 17, 2016, SNC provided a partial response to NRC's December 17,2015 RAI questions. SNC's letter answered questions #1 and #2, leaving the response to question #3 for a future date. Accordingly, the response to question #3 is provided in Enclosure 1 to this letter. Changes from the previous marked-up Technical Specifications resulted from the response.
Accordingly, Enclosures 2 and 3 provide the marked-up and the clean typed pages, respectively, to the revised LCO section, 3.8.1.
Additionally, on March 23, 2016, a teleconference was held between SNC and NRC staff to provide clarification, to NRC, on some of SNC's February 17 responses to the NRC's RAI of December 17,2015 . Accordingly, Enclosure 1 contains SNC's responses to the NRC's questions, which were provided to SNC prior to the call via electronic correspondence. The NRC's questions precede the SNC responses.
Finally, an oversight was recently discovered in the mark-up of LCO 3.7.14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function

U.S. Nuclear Regulatory Commission NL-16-0307 Page2 Condition should have been applied to this LCO but was not. Consequently, a mark-up and clean typed page is also included for this LCO.
This letter contains no NRC commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369.
Mr. C.R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
Respectfully submitted, c.tl~
I      1 C. R. Pierce                                                                      J Regulatory Affairs Director 1
CRP/OC V                                                                          I   I J,     '
i~ed before me this J~ ~ day of AP et     L-       '2016.
- ---1-------""""'~~ ) - -
Notary Public My commission expires: jo, 1 ~ 0 11

==Enclosures:==
: 1) Responses to Request for Additional Information
: 2) Marked up Technical Specifications Pages
: 3) Clean Typed Technical Specifications Pages cc:    Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice Preside nt- Fleet Operations Mr. M. D. Meier, Vice Preside nt- Regulatory Affairs Mr. B. K. Taber, Vice Preside nt- Vogtle 1 & 2 Mr. B. J. Adams, Vice Preside nt- Engineering Mr. G. W. Gunn, Regulatory Affairs Manag er- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manag er- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspect or- Vogtle 1 & 2 Mr. A.M. Alen, Resident Inspect or- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t
to Permit the use of Risk Informed Completion Times Enclosure 1 Responses to Request for Additional Information

Enclosure 1 to NL-16-0307 Response to Request for Additional Information Request for Additional Information Regarding Emergency Diesel Completion Times The Current Vogtle Technical Specification 3.8.1 contains the following requirements:
Vogtle TS Limiting Condition for Operation 3.8.1 specifies operability requirements for AC electrical sources. With one Diesel Generator (DG) inoperable, Condition 8 is applicable. Condition 8 requires, in part:
* Verify the Standby Auxiliary Transformer (SAT) is operable within 1 hour and once per 12 hours thereafter (Required Action 8.2); and, either
* Verify an enhanced black-start Combustion Turbine Generator (CTG) is functional by verifying the CTG and the black-start diesel generator starts and achieves steady state voltage and frequency within 72 hours or within 72 hours prior to entry into Condition 8 (Required Action 8.5.1)
                  -OR-
* Start and run at least one CTG while in Condition 8 within 72 hours or within 72 hours prior to entry into Condition 8 for preplanned maintenance (Required Action 8.5.2).
Additionally Condition 8 requires:
* Restore DG to operable status within 14 days from discovery of failure to meet LCO (Required Action 8.6).
LCO 3.8.1 Condition C applies when Required Actions 8.2, 8.5.1 or 8.5.2 and associated Completion Times are not met. Required Action C.1 requires:
* Restore DG to Operable Status within 72 hours.
If Required Action C.1 and its Completion Time are not met, the unit must be placed in Mode 3 within 6 hours and in Mode 5 within 36 hours.
Request for Additional Information:
The LAR proposes to add the option of either applying the existing front stop Completion Time or applying a Risk Informed Completion Time for Required Action C.1. The proposed change to the Completion Time for Required Action C.1 could permit operation for an extended period of time with one DG inoperable without verifying the availability of SAT or of the CTG. Please provide technical justification, including a discussion of defense-in-depth and safety margin considerations, for the addition of a risk-informed completion time for the Required Actions associated with LCO 3.8.1 Condition C, or propose a modification to the license amendment request that retains the existing CTs for verifying availability of SAT and functionality of a CTG.
E1-1

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response SNC has modified the license amendment request (LAR) to eliminate the current risk-informed Condition 8 and to apply a Risk-Informed Completion Time only to the Condition with the 72 hour front stop (current VEGP LCO 3.8.1, Condition C).
The new Condition 8 in the VEGP mark-up, Enclosure 2, matches Condition 8 in the NUREG-1431 mark-up for TSTF-505.
Enclosure 2 provides the marked-up Technical Specifications pages, including the change discussed above. For continuity, the entire RICT program mark-up is provided for LCO 3.8.1. Enclosure 3 provides the clean typed Technical Specifications pages; again for continuity, all RICT Program revised pages to date are included for LCO 3.8.1.
NRC Questions and SNC Responses from March 23, 2016 Teleconference NRC Question The response to RAI 1.b.ii states, The PRA Functional room cooling function is accomplished by opening doors instead of the room cooling system SSCs.
How is this consistent with the 1a response that, "SSCs credited in the PRA Functionality determination are the same SSCs relied on to perform the specified safety function ..."?
Is SNC specifically requesting NRC approval of alternate SSCs for use in establishing PRA functionality in this example? If so, are there any other similar instances in this LAR?
SNC Response Yes, SNC is specifically asking for approval for the use of manual action for opening ESF room doors for a TS Loss of Function (LOF) Condition inoperability related to "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System".
There are no similar instances in the LAR.
NRC Question Concerning the SNC response to RAI 2.a, The RAI requested, "Please confirm that the acceptable PRA Functional modelled in the PRA is also available and sufficient... "
The response states that SSCs will remain "available" but does not appear to address "sufficient." Was this an oversight or has sufficient capability to accomplish design basis functions not in the PRA not been evaluated or assured?
E1-2

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response Not addressing "sufficient" was an oversight.
The PRA Functionality evaluation performed following a TS LOF Condition will ensure that SSCs not supporting CDF/LERF will remain available, and will sufficiently perform their safety function with respect to the credited design basis scenario.
NRC Question The SNC Response to RAI 2.c states in part, For design basis initiators modeled in the internal events PRA, PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rates, temperature limits) are met.
Are the "design basis success criteria for parameters" identical to "the existing PRA success criteria"? If not, does this response to RAI 2.c supersede the August 2, 2013, SNC Response to NRC Question #4 quoted below?
Nevertheless, SNC will voluntarily include a summary of the Risk Informed Completion Time (RICT) program in Chapter 16 of the FSAR, 'Technical Specifications". This will include a section on PRA Functionality which will list those conditions which must be satisfied before declaring a component as "PRA Functional" per the NEI 06-09 Guidelines. The section will explicitly state that for a TS component to be considered PRA Functional, its PRA success criteria, among other things, must be satisfied. For example, EGGS flow rates satisfying the PRA criteria are determined by the existing PRA success criteria for that system. Therefore, should an EGGS become inoperable due to failing to meet its required TS SR Flow rate, its Functionality status would depend on whether or not the actual measured flow rate met the PRA success criteria.
SNC Response The response to RAI2.c provided in the February 17, 2016letter is valid for a TS LOF Condition inoperabilites. The response from the August 2, 2013 letter remains valid for non-LOF Condition inoperabilites.
Additional SNC Discovery Regarding LCO 3.7.14 An oversight was recently discovered in the mark-up of LCO 3. 7 .14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function (LOF) Condition should have been applied to this LCO but was not. Accordingly, Technical Specifications pages are included in this letter that add the LOF Condition. This LOF Condition (new Condition B) is consistent with proposed EXAMPLE 1.3-8 Condition B from the September 13, 2012 submittal and is consistent with other LOF Conditions added by the LAR.
E1-3

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 2 Marked-up Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7   PLANT SYSTEMS 3.7.14    Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14             Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.
                        ------------------------------------------NOTE---------------------------------------------
One Safety-Related Chiller train may be removed from service for
                        ~ 2 hours under administrative controls for surveillance testing of the other Safety-Related Chiller train.
APPLICABILITY :        MODES 1, 2, 3, and 4.
ACTIONS CONDITION                            REQUIRED ACTION                      COMPLETION TIME A. One ESF room cooler             A.1          Restore the ESF room             72 hours*
and safety-related chiller train inoperable.
cooler and safety-related         ,..___-1-' ~nsert 21 chiller train to OPERABLE Insert 1                            status.
Required Action and                          Be in MODE 3.                    6 hours Associated Completion Time not met.
36 hours
*For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.
Vogtle Units 1 and 2                                3.7.14-1

AC Sources - Operating 3.8.1 ACTIONS CONDITION         REQUIRED ACTION                  COMPLETION TIME A (continued)          A.2  Declare required feature(s)   24 hours from with no offsite power         discovery of no offsite available inoperable when     power to one train its redundant required        concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)
AND A.3  Restore required offsite      72 hours circuit to OPERABLE         /
status.                 /
(continued)
                     , --ln-s-ert-2--.,/
r--
Vogtle Units 1 and 2           3.8.1-2

AC Sources - Operating 3.8.1 CONDITION              REQUIRED ACTION                   COMPLETION TIME B. One DG inoperable. B.1       Perform SR 3.8.1.1 for the     1 hour required offsite circuit(s).
Once per 8 hours thereafter ANQ 8.2       Verify SAT available.
OnGe per 12 he1:1rs thereafter Declare required feature(s)   4 hours from supported by the              discovery of inoperable DG inoperable      Condition B when its required              concurrent with redundant feature(s) is inoperability of inoperable.
redundant required feature(s)
Determine OPERABLE DG is not inoperable due to       24 hours common cause failure.
OR
                             .2   Perform SR 3.8.1.2 for OPERABLE DG.                   24 hours (continued)
Vogtle Units 1 and 2                3.8.1-3

AC Sources - Operating 3.8.1 ACTIONS CONDITION          REQUIRED ACTION                                                         COMPLETION TIME lB.  (eontin~eel)l u+       lio...,.<:>JI
                                                                                                 ,I l72 ho~rij
                                 ,...,..; ,;..               +h....            rr lhl ... ,.      _... , ...,. ....             . .... n
                                                                  ..-~ ; ...,
                                                    ,~                                     ...~.
                                                                                               ~
                                 ,,.    ......... ,.             ~
I    OR!
ls.s.2    tt.tS Whf,:ln @Jnauf:9'.~                                            l72 ho~rij l2BI (continued)
Vogtle Units 1 and 2               3.8.1-4

AC Sources - Operating 3.8.1 Insert 2 ACTIONS CONDITION                      REQUIRED ACTION B.   (continued)                           Restore DG to OPERABLE         72 hour status.
  ~*   Req~;~i ree Actions B.2,  C.1         Restore DG to OPERABLE         72 t:lo~;~rs B.a.1, or B.5.2 ana                   stat~;~s .
associates Completion Times not met.
                                   .1       Declare required feature(s)    12 hours fro inoperable when its            discovery o redundant feature(s) is        Condition inoperable.                    concurrent with inoperability of redundant required features Restore one required           24 hours offsite circuit to OPERABLE status One required offsite      ----------------NOT E---------- -------
circuit inoperable.       Enter applicable Conditions and                                  Insert 2 Required Actions of LCO 3.8.9, "Distribution Systems - Operating ,"
when Condition          is entered with no One DG inoperable.        AC power sourc to one or more trains.
continued )
Vogtle Units 1 and 2                          3.8.1-5

AC Sources - Operating 3.8.1 CONDITION                         REQUIRED ACTION                        COMPLETION TIME (continued)                             Restore required offsite           12 hours circuit to OPERABLE status.
Insert 2a                                         .2    Restore DG to OPERABLE status .
                                                  .1    Restore one DG to OPERABLE status.
I. Three or FRere  req~:~ireel +:-1.+1---te=tR=Hte~erHb~C~O::J-.da'*
                                                                               . G*"".a~. lr:}:lFReeliately AC so~:~rses iROJ')erable.
Vogtle Units 1 and 2                            3.8.1-6

INSERT 1
------ --NO TE--- --------
Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.
B     Two ESF room cooler  8 .1 Restore one ESF         1 hour and safety-related        room cooler and chiller trains            safety-related chiller inoperable                train to OPERABLE status                 In accordance with the Risk Informed Completion Time Program

Insert 2 OR In accordance with the Risk Informed Completion Time Program

Insert 2a
-------------------------------------------------~C>lrE:--------------------------------------------------
~ot  applicable when second DG intentionally made inoperable

Insert 9 G. ---NOT E----           G.1   Restore required         1 hour Not applicable when          inoperable AC sources to three or more required       OPERABLE AC sources                   status.
intentionally made                                    In accordance with inoperable.                                           the Risk Informed Completion Time Program Three or more required AC sources inoperable.

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 3 Clean Typed Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7     PLANT SYSTEMS 3.7.14      Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14                 Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.
                            -------------------------------------------NOTE----------------------------------------------
One Safety-Related Chiller train may be removed from service for
                            ~ 2 hours under administrative controls for surveillance testing of the other Safety-Related Chiller train.
APPLICABILITY:            MODES 1, 2, 3, and 4.
ACTIONS CONDITION                               REQUIRED ACTION                       COMPLETION TIME A. One ESF room cooler                A.1          Restore the ESF room              72 hours*
and safety-related chiller                      cooler and safety-related train inoperable.                               chiller train to OPERABLE status.                           OR In accordance with the Risk Informed Completion Time Program
  ---------------NOTE--------------
Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.
B. Two ESF room cooler                B.1          Restore one ESF room              1 hour and safety-related chiller                      cooler and safety-related trains inoperable.                              chiller train to OPERABLE status.                           OR In accordance with the Risk Informed Completion Time Program
*For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.
Vogtle Units 1 and 2                                    3.7.14-1                   Amendment No.              (Unit 1)
Amendment No.              (Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 ACTIONS (continued)
CONDITION                         REQUIRED ACTION                 COMPLETION TIME C. Required Action and           C.1        Be in MODE 3.               6 hours Associated Completion Time not met.                 AND C.2        Be in MODE 5.               36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR 3.7.14.1        Verify each ESF room cooler and safety-related        In accordance with chiller system manual, power-operated and             the Surveillance automatic valve servicing safety-related              Frequency Control equipment that is not locked, sealed, or otherwise    Program secured in position, is in the correct position .
SR 3.7.14.2        Verify each ESF room cooler and safety-related        In accordance with chiller system automatic valve servicing safety-      the Surveillance related equipment that is not locked, sealed, or       Frequency Control otherwise secured in position actuates to the         Program correct position on an actual or simulated actuation signal.
SR 3.7 .14.3       Verify each ESF room cooler fan and safety-           In accordance with related chiller system (pump and chiller) start       the Surveillance automatically on an actual or simulated actuation     Frequency Control signal.                                               Program Vogtle Units 1 and 2                           3.7.14-2                Amend ment No.      (Unit 1)
Amend ment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTION S CONDITION     REQUIR ED ACTION                COMPL ETION TIME A (continued)      A.2  Declare required feature(s)   24 hours from with no offsite power         discover y of no offsite available inoperable when     power to one train its redundant required        concurre nt with feature(s) is inoperable. inoperability of redunda nt required feature(s)
AND A.3  Restore required offsite     72 hours circuit to OPERA BLE status.
In accorda nce with the Risk Informed Completion Time Program (continued)
Vogtle Units 1 and 2       3.8.1-2                Amendm ent No.      (Unit 1)
Amendm ent No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)
CONDITION               REQUIRED ACTION                    COMPLETION TIME B. One DG inoperable. 8.1      Perform SR 3.8.1.1 for the      1 hour required offsite circuit(s).
AND Once per 8 hours thereafter AND 8.2      Declare required feature(s)     4 hours from supported by the                discovery of inoperable DG inoperable        Condition B when its required               concurrent with redundant feature(s) is         inoperability of inoperable.                     redundant required feature(s)
AND B.3.1    Determine OPERABLE DG          24 hours is not inoperable due to common cause failure.
OR B.3.2    Perform SR 3.8.1.2 for         24 hours OPERABLE DG.
AND (continued)
Vogtle Units 1 and 2                 3.8.1-3                  Amendment No.      (Unit 1)
Amendment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION                    REQUIRED ACTION                        COMPLETION TIME B.    (continued)          B.4          Restore DG to OPERABLE              72 hours status.
OR In accordance with the Risk Informed Completion Time Program C. Two required offsite  c. 1         Declare required feature(s)         12 hours from circuits inoperable.               inoperable when its                discovery of redundant feature(s) is            Condition C inoperable.                        concurrent with inoperability of redundant required AND                                              features C.2           Restore one required               24 hours offsite circuit to OPERABLE status                    OR In accordance with the Risk Informed Completion Time Program D. One required offsite --------------------N 0 TE -------------------
circuit inoperable. Enter applicable Condition? and Required Actions of LCO 3.8.9, AND                  "Distribution Systems- Operating,"
when Condition D is entered with no One DG inoperable. AC power source to one or more trains.
(continued)
Vogtle Units 1 and 2                       3.8.1-4                      Amendment No.     (Unit 1)
Amendment No.     (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION                      REQUIRED ACTION                  COMPLETION TIME D.    (continued)                   D.1    Restore required offsite      12 hours circuit to OPERABLE status.                       OR OR                                  In accordance with the Risk Informed Completion Time Program 0 .2  Restore DG to OPERABLE        12 hours status.
OR In accordance with the Risk Informed Completion Time Program
 ---------------NOTE-------------
Not applicable when second DG intentionally made inoperable.
E. Two DGs inoperable.            E.1   Restore one DG to            2 hours OPERABLE status.
OR In accordance with the Risk Informed Completion Time Program F. One automatic load             F.1   Restore automatic load       12 hours sequencer inoperable.                sequencer to OPERABLE status.                      OR In accordance with the Risk Informed Completion Time Program (continued)
Vogtle Units 1 and 2                          3.8.1-5                Amendment No.      (Unit 1)
Amendment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)
CONDITION                REQUIRED ACTION              COMPLETION TIME G.    --------NOTE----------- G. 1  Restore required           1 hour Not applicable when           inoperable AC sources to three or more required        OPERABLE status.          OR AC sources intentionally made                                      In accordance with inoperable.                                             the Risk Informed
        -----------------------                                 Completion Time Three or more required                                  Program AC sources inoperable.
H. Required Action and      H.1   Be in MODE 3.             6 hours associated Completion Time of Condition A, B,  AND C, D, E, F, or G not m~t.                     H.2   Be in MODE 5.             36 hours Vogtle Units 1 and 2                   3.8.1-6             Amendment No.     (Unit 1)
Amendment No.     (Unit 2)

Charles R. Pierce               Southern Nuclear Regulatory Affairs Director     Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205 992.7601                  SOUTHERN * \
NUCLEAR A SOUTHER N COMPAN Y Docket Nos.: 50-424                                                   NL-16-0307 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t
to Permit the use of Risk Informed Completion Times Ladies and Gentlemen:
By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request to permit the use of Risk Informe d
Technical Specification (TS) Completion Times in accordance with Nuclear Energy Institute (NEI) Report 06-09, Revision 0, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)
Guidelines, at the Vogtle Electric Generating Station. The SNC submittal was supplemented by letters dated August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, and May 5, 2015. By letter dated December 17, 2015, the Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) regarding the SNC TS amendment request.
By letter dated February 17, 2016, SNC provided a partial response to NRC's December 17,2015 RAI questions. SNC's letter answered questions #1 and #2, leaving the response to question #3 for a future date. Accordingly, the response to question #3 is provided in Enclosure 1 to this letter. Changes from the previous marked-up Technical Specifications resulted from the response.
Accordingly, Enclosures 2 and 3 provide the marked-up and the clean typed pages, respectively, to the revised LCO section, 3.8.1.
Additionally, on March 23, 2016, a teleconference was held between SNC and NRC staff to provide clarification, to NRC, on some of SNC's February 17 responses to the NRC's RAI of December 17,2015 . Accordingly, Enclosure 1 contains SNC's responses to the NRC's questions, which were provided to SNC prior to the call via electronic correspondence. The NRC's questions precede the SNC responses.
Finally, an oversight was recently discovered in the mark-up of LCO 3.7.14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function

U.S. Nuclear Regulatory Commission NL-16-0307 Page2 Condition should have been applied to this LCO but was not. Consequently, a mark-up and clean typed page is also included for this LCO.
This letter contains no NRC commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369.
Mr. C.R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
Respectfully submitted, c.tl~
I      1 C. R. Pierce                                                                      J Regulatory Affairs Director 1
CRP/OC V                                                                          I   I J,     '
i~ed before me this J~ ~ day of AP et     L-       '2016.
- ---1-------""""'~~ ) - -
Notary Public My commission expires: jo, 1 ~ 0 11

==Enclosures:==
: 1) Responses to Request for Additional Information
: 2) Marked up Technical Specifications Pages
: 3) Clean Typed Technical Specifications Pages cc:    Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice Preside nt- Fleet Operations Mr. M. D. Meier, Vice Preside nt- Regulatory Affairs Mr. B. K. Taber, Vice Preside nt- Vogtle 1 & 2 Mr. B. J. Adams, Vice Preside nt- Engineering Mr. G. W. Gunn, Regulatory Affairs Manag er- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manag er- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspect or- Vogtle 1 & 2 Mr. A.M. Alen, Resident Inspect or- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t
to Permit the use of Risk Informed Completion Times Enclosure 1 Responses to Request for Additional Information

Enclosure 1 to NL-16-0307 Response to Request for Additional Information Request for Additional Information Regarding Emergency Diesel Completion Times The Current Vogtle Technical Specification 3.8.1 contains the following requirements:
Vogtle TS Limiting Condition for Operation 3.8.1 specifies operability requirements for AC electrical sources. With one Diesel Generator (DG) inoperable, Condition 8 is applicable. Condition 8 requires, in part:
* Verify the Standby Auxiliary Transformer (SAT) is operable within 1 hour and once per 12 hours thereafter (Required Action 8.2); and, either
* Verify an enhanced black-start Combustion Turbine Generator (CTG) is functional by verifying the CTG and the black-start diesel generator starts and achieves steady state voltage and frequency within 72 hours or within 72 hours prior to entry into Condition 8 (Required Action 8.5.1)
                  -OR-
* Start and run at least one CTG while in Condition 8 within 72 hours or within 72 hours prior to entry into Condition 8 for preplanned maintenance (Required Action 8.5.2).
Additionally Condition 8 requires:
* Restore DG to operable status within 14 days from discovery of failure to meet LCO (Required Action 8.6).
LCO 3.8.1 Condition C applies when Required Actions 8.2, 8.5.1 or 8.5.2 and associated Completion Times are not met. Required Action C.1 requires:
* Restore DG to Operable Status within 72 hours.
If Required Action C.1 and its Completion Time are not met, the unit must be placed in Mode 3 within 6 hours and in Mode 5 within 36 hours.
Request for Additional Information:
The LAR proposes to add the option of either applying the existing front stop Completion Time or applying a Risk Informed Completion Time for Required Action C.1. The proposed change to the Completion Time for Required Action C.1 could permit operation for an extended period of time with one DG inoperable without verifying the availability of SAT or of the CTG. Please provide technical justification, including a discussion of defense-in-depth and safety margin considerations, for the addition of a risk-informed completion time for the Required Actions associated with LCO 3.8.1 Condition C, or propose a modification to the license amendment request that retains the existing CTs for verifying availability of SAT and functionality of a CTG.
E1-1

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response SNC has modified the license amendment request (LAR) to eliminate the current risk-informed Condition 8 and to apply a Risk-Informed Completion Time only to the Condition with the 72 hour front stop (current VEGP LCO 3.8.1, Condition C).
The new Condition 8 in the VEGP mark-up, Enclosure 2, matches Condition 8 in the NUREG-1431 mark-up for TSTF-505.
Enclosure 2 provides the marked-up Technical Specifications pages, including the change discussed above. For continuity, the entire RICT program mark-up is provided for LCO 3.8.1. Enclosure 3 provides the clean typed Technical Specifications pages; again for continuity, all RICT Program revised pages to date are included for LCO 3.8.1.
NRC Questions and SNC Responses from March 23, 2016 Teleconference NRC Question The response to RAI 1.b.ii states, The PRA Functional room cooling function is accomplished by opening doors instead of the room cooling system SSCs.
How is this consistent with the 1a response that, "SSCs credited in the PRA Functionality determination are the same SSCs relied on to perform the specified safety function ..."?
Is SNC specifically requesting NRC approval of alternate SSCs for use in establishing PRA functionality in this example? If so, are there any other similar instances in this LAR?
SNC Response Yes, SNC is specifically asking for approval for the use of manual action for opening ESF room doors for a TS Loss of Function (LOF) Condition inoperability related to "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System".
There are no similar instances in the LAR.
NRC Question Concerning the SNC response to RAI 2.a, The RAI requested, "Please confirm that the acceptable PRA Functional modelled in the PRA is also available and sufficient... "
The response states that SSCs will remain "available" but does not appear to address "sufficient." Was this an oversight or has sufficient capability to accomplish design basis functions not in the PRA not been evaluated or assured?
E1-2

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response Not addressing "sufficient" was an oversight.
The PRA Functionality evaluation performed following a TS LOF Condition will ensure that SSCs not supporting CDF/LERF will remain available, and will sufficiently perform their safety function with respect to the credited design basis scenario.
NRC Question The SNC Response to RAI 2.c states in part, For design basis initiators modeled in the internal events PRA, PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rates, temperature limits) are met.
Are the "design basis success criteria for parameters" identical to "the existing PRA success criteria"? If not, does this response to RAI 2.c supersede the August 2, 2013, SNC Response to NRC Question #4 quoted below?
Nevertheless, SNC will voluntarily include a summary of the Risk Informed Completion Time (RICT) program in Chapter 16 of the FSAR, 'Technical Specifications". This will include a section on PRA Functionality which will list those conditions which must be satisfied before declaring a component as "PRA Functional" per the NEI 06-09 Guidelines. The section will explicitly state that for a TS component to be considered PRA Functional, its PRA success criteria, among other things, must be satisfied. For example, EGGS flow rates satisfying the PRA criteria are determined by the existing PRA success criteria for that system. Therefore, should an EGGS become inoperable due to failing to meet its required TS SR Flow rate, its Functionality status would depend on whether or not the actual measured flow rate met the PRA success criteria.
SNC Response The response to RAI2.c provided in the February 17, 2016letter is valid for a TS LOF Condition inoperabilites. The response from the August 2, 2013 letter remains valid for non-LOF Condition inoperabilites.
Additional SNC Discovery Regarding LCO 3.7.14 An oversight was recently discovered in the mark-up of LCO 3. 7 .14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function (LOF) Condition should have been applied to this LCO but was not. Accordingly, Technical Specifications pages are included in this letter that add the LOF Condition. This LOF Condition (new Condition B) is consistent with proposed EXAMPLE 1.3-8 Condition B from the September 13, 2012 submittal and is consistent with other LOF Conditions added by the LAR.
E1-3

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 2 Marked-up Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7   PLANT SYSTEMS 3.7.14    Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14             Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.
                        ------------------------------------------NOTE---------------------------------------------
One Safety-Related Chiller train may be removed from service for
                        ~ 2 hours under administrative controls for surveillance testing of the other Safety-Related Chiller train.
APPLICABILITY :        MODES 1, 2, 3, and 4.
ACTIONS CONDITION                            REQUIRED ACTION                      COMPLETION TIME A. One ESF room cooler             A.1          Restore the ESF room             72 hours*
and safety-related chiller train inoperable.
cooler and safety-related         ,..___-1-' ~nsert 21 chiller train to OPERABLE Insert 1                            status.
Required Action and                          Be in MODE 3.                    6 hours Associated Completion Time not met.
36 hours
*For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.
Vogtle Units 1 and 2                                3.7.14-1

AC Sources - Operating 3.8.1 ACTIONS CONDITION         REQUIRED ACTION                  COMPLETION TIME A (continued)          A.2  Declare required feature(s)   24 hours from with no offsite power         discovery of no offsite available inoperable when     power to one train its redundant required        concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)
AND A.3  Restore required offsite      72 hours circuit to OPERABLE         /
status.                 /
(continued)
                     , --ln-s-ert-2--.,/
r--
Vogtle Units 1 and 2           3.8.1-2

AC Sources - Operating 3.8.1 CONDITION              REQUIRED ACTION                   COMPLETION TIME B. One DG inoperable. B.1       Perform SR 3.8.1.1 for the     1 hour required offsite circuit(s).
Once per 8 hours thereafter ANQ 8.2       Verify SAT available.
OnGe per 12 he1:1rs thereafter Declare required feature(s)   4 hours from supported by the              discovery of inoperable DG inoperable      Condition B when its required              concurrent with redundant feature(s) is inoperability of inoperable.
redundant required feature(s)
Determine OPERABLE DG is not inoperable due to       24 hours common cause failure.
OR
                             .2   Perform SR 3.8.1.2 for OPERABLE DG.                   24 hours (continued)
Vogtle Units 1 and 2                3.8.1-3

AC Sources - Operating 3.8.1 ACTIONS CONDITION          REQUIRED ACTION                                                         COMPLETION TIME lB.  (eontin~eel)l u+       lio...,.<:>JI
                                                                                                 ,I l72 ho~rij
                                 ,...,..; ,;..               +h....            rr lhl ... ,.      _... , ...,. ....             . .... n
                                                                  ..-~ ; ...,
                                                    ,~                                     ...~.
                                                                                               ~
                                 ,,.    ......... ,.             ~
I    OR!
ls.s.2    tt.tS Whf,:ln @Jnauf:9'.~                                            l72 ho~rij l2BI (continued)
Vogtle Units 1 and 2               3.8.1-4

AC Sources - Operating 3.8.1 Insert 2 ACTIONS CONDITION                      REQUIRED ACTION B.   (continued)                           Restore DG to OPERABLE         72 hour status.
  ~*   Req~;~i ree Actions B.2,  C.1         Restore DG to OPERABLE         72 t:lo~;~rs B.a.1, or B.5.2 ana                   stat~;~s .
associates Completion Times not met.
                                   .1       Declare required feature(s)    12 hours fro inoperable when its            discovery o redundant feature(s) is        Condition inoperable.                    concurrent with inoperability of redundant required features Restore one required           24 hours offsite circuit to OPERABLE status One required offsite      ----------------NOT E---------- -------
circuit inoperable.       Enter applicable Conditions and                                  Insert 2 Required Actions of LCO 3.8.9, "Distribution Systems - Operating ,"
when Condition          is entered with no One DG inoperable.        AC power sourc to one or more trains.
continued )
Vogtle Units 1 and 2                          3.8.1-5

AC Sources - Operating 3.8.1 CONDITION                         REQUIRED ACTION                        COMPLETION TIME (continued)                             Restore required offsite           12 hours circuit to OPERABLE status.
Insert 2a                                         .2    Restore DG to OPERABLE status .
                                                  .1    Restore one DG to OPERABLE status.
I. Three or FRere  req~:~ireel +:-1.+1---te=tR=Hte~erHb~C~O::J-.da'*
                                                                               . G*"".a~. lr:}:lFReeliately AC so~:~rses iROJ')erable.
Vogtle Units 1 and 2                            3.8.1-6

INSERT 1
------ --NO TE--- --------
Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.
B     Two ESF room cooler  8 .1 Restore one ESF         1 hour and safety-related        room cooler and chiller trains            safety-related chiller inoperable                train to OPERABLE status                 In accordance with the Risk Informed Completion Time Program

Insert 2 OR In accordance with the Risk Informed Completion Time Program

Insert 2a
-------------------------------------------------~C>lrE:--------------------------------------------------
~ot  applicable when second DG intentionally made inoperable

Insert 9 G. ---NOT E----           G.1   Restore required         1 hour Not applicable when          inoperable AC sources to three or more required       OPERABLE AC sources                   status.
intentionally made                                    In accordance with inoperable.                                           the Risk Informed Completion Time Program Three or more required AC sources inoperable.

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 3 Clean Typed Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7     PLANT SYSTEMS 3.7.14      Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14                 Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.
                            -------------------------------------------NOTE----------------------------------------------
One Safety-Related Chiller train may be removed from service for
                            ~ 2 hours under administrative controls for surveillance testing of the other Safety-Related Chiller train.
APPLICABILITY:            MODES 1, 2, 3, and 4.
ACTIONS CONDITION                               REQUIRED ACTION                       COMPLETION TIME A. One ESF room cooler                A.1          Restore the ESF room              72 hours*
and safety-related chiller                      cooler and safety-related train inoperable.                               chiller train to OPERABLE status.                           OR In accordance with the Risk Informed Completion Time Program
  ---------------NOTE--------------
Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.
B. Two ESF room cooler                B.1          Restore one ESF room              1 hour and safety-related chiller                      cooler and safety-related trains inoperable.                              chiller train to OPERABLE status.                           OR In accordance with the Risk Informed Completion Time Program
*For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.
Vogtle Units 1 and 2                                    3.7.14-1                   Amendment No.              (Unit 1)
Amendment No.              (Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 ACTIONS (continued)
CONDITION                         REQUIRED ACTION                 COMPLETION TIME C. Required Action and           C.1        Be in MODE 3.               6 hours Associated Completion Time not met.                 AND C.2        Be in MODE 5.               36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR 3.7.14.1        Verify each ESF room cooler and safety-related        In accordance with chiller system manual, power-operated and             the Surveillance automatic valve servicing safety-related              Frequency Control equipment that is not locked, sealed, or otherwise    Program secured in position, is in the correct position .
SR 3.7.14.2        Verify each ESF room cooler and safety-related        In accordance with chiller system automatic valve servicing safety-      the Surveillance related equipment that is not locked, sealed, or       Frequency Control otherwise secured in position actuates to the         Program correct position on an actual or simulated actuation signal.
SR 3.7 .14.3       Verify each ESF room cooler fan and safety-           In accordance with related chiller system (pump and chiller) start       the Surveillance automatically on an actual or simulated actuation     Frequency Control signal.                                               Program Vogtle Units 1 and 2                           3.7.14-2                Amend ment No.      (Unit 1)
Amend ment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTION S CONDITION     REQUIR ED ACTION                COMPL ETION TIME A (continued)      A.2  Declare required feature(s)   24 hours from with no offsite power         discover y of no offsite available inoperable when     power to one train its redundant required        concurre nt with feature(s) is inoperable. inoperability of redunda nt required feature(s)
AND A.3  Restore required offsite     72 hours circuit to OPERA BLE status.
In accorda nce with the Risk Informed Completion Time Program (continued)
Vogtle Units 1 and 2       3.8.1-2                Amendm ent No.      (Unit 1)
Amendm ent No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)
CONDITION               REQUIRED ACTION                    COMPLETION TIME B. One DG inoperable. 8.1      Perform SR 3.8.1.1 for the      1 hour required offsite circuit(s).
AND Once per 8 hours thereafter AND 8.2      Declare required feature(s)     4 hours from supported by the                discovery of inoperable DG inoperable        Condition B when its required               concurrent with redundant feature(s) is         inoperability of inoperable.                     redundant required feature(s)
AND B.3.1    Determine OPERABLE DG          24 hours is not inoperable due to common cause failure.
OR B.3.2    Perform SR 3.8.1.2 for         24 hours OPERABLE DG.
AND (continued)
Vogtle Units 1 and 2                 3.8.1-3                  Amendment No.      (Unit 1)
Amendment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION                    REQUIRED ACTION                        COMPLETION TIME B.    (continued)          B.4          Restore DG to OPERABLE              72 hours status.
OR In accordance with the Risk Informed Completion Time Program C. Two required offsite  c. 1         Declare required feature(s)         12 hours from circuits inoperable.               inoperable when its                discovery of redundant feature(s) is            Condition C inoperable.                        concurrent with inoperability of redundant required AND                                              features C.2           Restore one required               24 hours offsite circuit to OPERABLE status                    OR In accordance with the Risk Informed Completion Time Program D. One required offsite --------------------N 0 TE -------------------
circuit inoperable. Enter applicable Condition? and Required Actions of LCO 3.8.9, AND                  "Distribution Systems- Operating,"
when Condition D is entered with no One DG inoperable. AC power source to one or more trains.
(continued)
Vogtle Units 1 and 2                       3.8.1-4                      Amendment No.     (Unit 1)
Amendment No.     (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION                      REQUIRED ACTION                  COMPLETION TIME D.    (continued)                   D.1    Restore required offsite      12 hours circuit to OPERABLE status.                       OR OR                                  In accordance with the Risk Informed Completion Time Program 0 .2  Restore DG to OPERABLE        12 hours status.
OR In accordance with the Risk Informed Completion Time Program
 ---------------NOTE-------------
Not applicable when second DG intentionally made inoperable.
E. Two DGs inoperable.            E.1   Restore one DG to            2 hours OPERABLE status.
OR In accordance with the Risk Informed Completion Time Program F. One automatic load             F.1   Restore automatic load       12 hours sequencer inoperable.                sequencer to OPERABLE status.                      OR In accordance with the Risk Informed Completion Time Program (continued)
Vogtle Units 1 and 2                          3.8.1-5                Amendment No.      (Unit 1)
Amendment No.      (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)
CONDITION                REQUIRED ACTION              COMPLETION TIME G.    --------NOTE----------- G. 1  Restore required           1 hour Not applicable when           inoperable AC sources to three or more required        OPERABLE status.          OR AC sources intentionally made                                      In accordance with inoperable.                                             the Risk Informed
        -----------------------                                 Completion Time Three or more required                                  Program AC sources inoperable.
H. Required Action and      H.1   Be in MODE 3.             6 hours associated Completion Time of Condition A, B,  AND C, D, E, F, or G not m~t.                     H.2   Be in MODE 5.             36 hours Vogtle Units 1 and 2                   3.8.1-6             Amendment No.     (Unit 1)
Amendment No.     (Unit 2)}}